Top Questions

In accordance with the definition of an indirect payment at 42 C.F.R. §403.902, an applicable manufacturer that contr... (more)

In accordance with the definition of an indirect payment at 42 C.F.R. §403.902, an applicable manufacturer that contributes funding to a medical/educational conference would be required to report the payment if the reporting entity determines that it meets the definition of an indirect payment at 42 C.F.R. §403.902. An indirect payment is defined at 42 C.F.R. §403.902 as a payment or other transfer of value made by an applicable manufacturer to a covered recipient through a third party, where the applicable manufacturer requires, instructs, directs, or otherwise causes the third party to provide the payment or transfer of value, in whole or in part, to a covered recipient. Indirect payments that the reporting entity determines do not meet the definition at 42 C.F.R. §403.902 are excluded from reporting.

Starting with 2016 data collection and reporting to CMS in 2017, indirect payments provided by an applicable manufact... (more)

Starting with 2016 data collection and reporting to CMS in 2017, indirect payments provided by an applicable manufacturer to a continuing education organization are reportable if the manufacturer determines that it meets the definition of an indirect payment. An indirect payment is defined at 42 C.F.R. §403.902 as a payment or other transfer of value made by an applicable manufacturer to a covered recipient through a third party, where the applicable manufacturer requires, instructs, directs, or otherwise causes the third party to provide the payment or transfer of value, in whole or in part, to a covered recipient.

In accordance with the definition of an indirect payment at 42 C.F.R. §403.902, applicable manufacturers that contrib... (more)

In accordance with the definition of an indirect payment at 42 C.F.R. §403.902, applicable manufacturers that contribute funding to a CME program with several speakers are required to report the payments provided to physician speakers if they determine that the payments meet the definition of an indirect payment. An indirect payment is defined at 42 C.F.R. §403.902 as a payment or other transfer of value made by an applicable manufacturer to a covered recipient through a third party, where the applicable manufacturer requires, instructs, directs, or otherwise causes the third party to provide the payment or transfer of value, in whole or in part, to a covered recipient.

CMS will investigate whether the EP, CPC practice site, or group practice or ACO participating via GPRO met the criteria for satisfactorily reporting under PQRS to either receive an incentive or avoid the negative payment adjustment. The informal review decision is final and there will be no further review.

Informal reviews may only be submitted via the Quality Reporting Communication Support Page (CSP) between January 1, 2015 and February 28, 2015. CMS will announce the availability of this page through MLN Connects Provider eNews and the PQRS Listserv. All informal review requests must be submitted electronically through the CSP.

Services furnished by RHCs and FQHCs are not eligible for the PQRS incentive payment and are not subject to the PQRS neg... (more)

Services furnished by RHCs and FQHCs are not eligible for the PQRS incentive payment and are not subject to the PQRS negative payment adjustment. Only covered professional services furnished by eligible health care professionals (EPs) that are paid under the Medicare Physician Fee Schedule (MPFS) are eligible for PQRS.

Please review the Tax Identification Number (TIN)/National Provider Identifier (NPI) combination included in the letter received from CMS, as this is the individual provider to whom the 2015 payment adjustment will apply, not the clinic or facility. An example of why a physician who practices at an RHC/FQHC may be subject to the 2015 payment adjustment is that (s)he bills non-RHC or non-FQHC services under the MPFS via the 1500 claim form. The provider’s contact information used to send the 2015 PQRS negative payment adjustment letters was gathered from the Provider Enrollment, Chain, and Ownership System (PECOS). Letters that include only a TIN apply to the entire group practice as the TIN is registered to participate in the 2013 PQRS GPRO. The group’s contact information used to send the 2015 PQRS negative payment adjustment letters was gathered from the 2013 PQRS GPRO registration or self-nomination system.

CMS would also like to remind participants that there are no hardship or low volume exemptions for the PQRS payment adjustment. All EPs who billed Medicare Part B for non-RHC/FQHC services in 2013 must have satisfactorily reported PQRS in order to avoid the 2015 negative payment adjustment.

As outlined in the 2015 PQRS payment adjustment letter, if you believe that the 2015 PQRS payment adjustment is being applied in error, you can submit an informal review request. All informal review requests must be submitted via a web-based tool, the Quality Reporting Communication Support Page (Communication Support Page), during the informal review period, January 1, 2015 through February 28, 2015.

Please contact the QualityNet Help Desk at 1-866-288-8912 (TTY 1-877-715-6222) or via qnetsupport@hcqis.org for help with questions. They are available from 7:00 a.m. to 7:00 p.m. Central Time Monday through Friday.

In the fall of 2014, CMS disseminated physician feedback reports, called Quality Reporting and Usage Reports (QRURs), containing CY 2013 data to groups of physicians subject to the VM. These reports will be the basis of the VM in 2015. After receiving their QRURs, physicians may e-mail or call a technical help desk to inquire about their report and the calculation of the VM. CMS has adopted this process to help educate and inform physicians about the Value Modifier, especially for those groups of physicians that have elected to have their VM calculated using a quality-tiering approach.

Questions about the Value Modifier can be directed to the Physician Value (PV) Help Desk at 1-888-734-6433, press option 3 (TTY 1-888-734-6563) or by email to pvhelpdesk@cms.hhs.gov Monday – Friday: 8:00 a.m. – 8:00 p.m. EST.

The PQRS, MU, and VM, payment adjustments will apply to all eligible professional’s (EP’s) Part B covered professiona... (more)

The PQRS, MU, and VM, payment adjustments will apply to all eligible professional’s (EP’s) Part B covered professional services. Covered professional services are defined as services furnished by an EP for which payment is made under, or is based on, the Medicare Physician Fee Schedule (MPFS) as provided in section 1848(k)(3) of the Act. Because the payment adjustment only applies to Part B MPFS claims and Part B drugs are not paid on the MPFS, the actual drug is not subjected to the payment adjustment. However, the administration of drugs by an EP is subject to the payment adjustment. For example, J2778 (Lucentis) would not be subjected to the payment adjustment but 67028 (intravitreal injection), would be subjected to the payment adjustment.

To submit the request, go to the Quality Reporting Communication Support Page (CSP), which will be available January 1, 2015 through February 28, 2015. CMS will announce the availability of this page through MLN Connects Provider eNews, the PQRS Listserv, and other related CMS listservs. All informal review requests must be submitted electronically through the CSP. The informal review decision is final and there will be no further review.

For those EPs who participated in 2013 PQRS via a data submission vendor or qualified registry, the request for an informal review must be made by the vendor or registry that submitted the data on behalf of their client. One request will need to be submitted for each TIN/NPI under which they would like CMS to conduct an informal review. The informal review decision will be sent to the applicable provider and not to the registry or EHR vendor.

For questions, contact the QualityNet Help Desk at 1-866-288-8912 (TTY 1-877-715-6222) or by email to qnetsupport@hcqis.org Monday through Friday, from 7:00 a.m. – 7:00 p.m. CT.

If you are an eligible professional (EP) or group practice who participated in the 2013 PQRS and believe that your 2013 ... (more)

If you are an eligible professional (EP) or group practice who participated in the 2013 PQRS and believe that your 2013 PQRS feedback report, incentive payment OR the 2015 PQRS Payment Adjustment is incorrect, you may submit a request for an informal review to CMS.

All informal review requests must be submitted electronically through the Communication Support Page (CSP) between January 1, 2015 and February 28, 2015. Eligible professionals who did not satisfactorily report 2013 data on quality measures for covered professional services will be subject to a payment adjustment under PQRS beginning in 2015.

For questions, contact the QualityNet Help Desk at 1-866-288-8912 (TTY 1-877-715-6222) or by email to qnetsupport@hcqis.org Monday through Friday, from 7:00 a.m. – 7:00 p.m. CT.

One point of contact for the group practice reporting via PQRS GPRO will need to request an informal review. The info... (more)

One point of contact for the group practice reporting via PQRS GPRO will need to request an informal review. The informal review will need to be submitted for the TIN under which the group practice participating via GPRO or Accountable Care Organizations (ACOs) participating via GPRO submitted 2013 PQRS data.

To submit the request, go to the Quality Reporting Communication Support Page (CSP), which will be available January 1, 2015 through February 28, 2015. CMS will announce the availability of this page through MLN Connects Provider eNews and the PQRS Listserv. All informal review requests must be submitted electronically through the CSP. The informal review decision is final and there will be no further review.

Eligible professionals who did not satisfactorily report data on 2013 quality measures for covered professional services will be subject to a payment adjustment under PQRS beginning in 2015.

For questions, contact the QualityNet Help Desk at 1-866-288-8912 (TTY 1-877-715-6222) or by email to qnetsupport@hcqis.orgMonday through Friday, from 7:00 a.m. – 7:00 p.m. CT.

If you are an eligible professional (EP) or group practice who participated in the 2013 eRx Incentive Program and believ... (more)

If you are an eligible professional (EP) or group practice who participated in the 2013 eRx Incentive Program and believe that your 2013 feedback report or incentive payment is incorrect, you may submit a request for an informal review to CMS.

Individual eligible professionals (EPs) or designated support staff will need to submit a request for an informal review for each individual rendering National Provider Identifier (NPI) for each Tax Identification Number (TIN) under which the requestor reported 2013 PQRS (quality-data codes (QDCs) via claims or submitted data via qualified registry or electronic health record [EHR]).

If an eligible professional (EP) satisfactorily reports for 2014 PQRS using the EHR-based reporting option, (s)he wil... (more)

If an eligible professional (EP) satisfactorily reports for 2014 PQRS using the EHR-based reporting option, (s)he will also satisfy the clinical quality measure (CQM) component of the EHR Incentive program; however, EPs will still be required to meet the other Meaningful Use objectives through the Medicare EHR Incentive Program Registration and Attestation System.

To submit a PQRS informal review request, go to the Quality Reporting Communication Support Page (CSP), which will be available January 1, 2015 through February 28, 2015. CMS will announce the availability of this page through MLN Connects Provider eNews and the PQRS Listserv. All informal review requests must be submitted electronically through the CSP. The informal review decision is final and there will be no further review.
Medicare EPs can use the EHR Incentive Program Attestation Module to view their attestation status. If they have demonstrated meaningful use of certified EHR technology, their attestation is accepted. If they did not meet one or more of the meaningful use minimum standards, their attestation is rejected. CMS also posts quarterly reports of providers that are meaningful users who are receiving an incentive payment.
EPs can apply for an EHR Incentive Program payment adjustment reconsideration if they think their payment adjustment determination was made in error.

To begin the process, EPs must complete the appropriate application and follow the instructions, as found on the CMS EHR Incentive Program website. The payment adjustment reconsideration application must be submitted electronically by 11:59 PM ET, February 28, 2015. The filing request and supporting documentation must be submitted electronically to pareconsideration@provider-resources.com. The request will only be processed if all documentation is provided at the time of submission.
See CMS EHR Incentive Program website for more information. Questions can be directed to the EHR Incentive Program Information Center at 888-734-6433 (TTY 888-734-6563).

For PQRS questions, contact the QualityNet Help Desk at 1-866-288-8912 (TTY 1-877-715-6222) or by email to qnetsupport@hcqis.org Monday through Friday, from 7:00 a.m. – 7:00 p.m. CT.

CPC practice sites that have elected the PQRS waiver and are requesting an informal review should submit one request for... (more)

CPC practice sites that have elected the PQRS waiver and are requesting an informal review should submit one request for each TIN/NPI within the CPC practice site. Please be sure to enter the CPC practice site ID number in the text field provided as this will ensure that the informal review is applied to all CPC eligible professionals (EPs) who were active at the practice site in 2013. Informal review requests will be automatically denied for those CPC practice sites that elected the PQRS waiver and received a 2013 PQRS incentive payment.

CPC practice sites that did not elect the PQRS waiver, but would like to request an informal review, can do so via the method under which they reported to PQRS (e.g., group practice participating in the group practice reporting option [GPRO] or individual EP).

To submit the request, go to the Quality Reporting Communication Support Page (CSP), which will be available January 1, 2015 through February 28, 2015. CMS will announce the availability of this page through MLN Connects Provider eNews, the PQRS Listserv, and other related CMS listservs. All informal review requests must be submitted electronically through the CSP. The informal review decision is final, and there will be no further review.

For questions related to CPC, please contact CPC Support (cpcisupport@telligen.org or 800-381-4724).

For other PQRS questions, contact the QualityNet Help Desk at 1-866-288-8912 (TTY 1-877-715-6222) or by email to qnetsupport@hcqis.org Monday through Friday, from 7:00 a.m. – 7:00 p.m. CT.

Reporting entities should only submit the newly corrected records. They should not re-upload an entire new data file,... (more)

Reporting entities should only submit the newly corrected records. They should not re-upload an entire new data file, which includes the corrected record plus previously submitted records that did not need to be corrected. Re-uploading an entire new data file that includes records that did not need to be corrected may not be in compliance with 42 C.F.R. § 403.908(e), which pertains to attesting to each report, including subsequent corrections, and ensuring the submission is reported timely, accurately, and is a complete submission.

The IRS Form CP 575 is an Internal Revenue Service generated letter you receive from the IRS granting your Employer Iden... (more)

The IRS Form CP 575 is an Internal Revenue Service generated letter you receive from the IRS granting your Employer Identification Number (EIN) linking it with your legal business name (LBN). A copy of your CP 575 may be required by the Medicare contractor to verify the provider or supplier’s EIN and LBN. Any other IRS document showing the provider or supplier's EIN and LBN is also acceptable for enrollent purposes. (FAQ2009)
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Interpret the phrase "new patient" to mean a patient who has not received any professional services, i.e., evaluation an... (more)

Interpret the phrase "new patient" to mean a patient who has not received any professional services, i.e., evaluation and management service or other face-to-face service (e.g., surgical procedure) from the physician or physician group practice (same physician specialty) within the previous three years. For example, if a professional component of a previous procedure is billed in a 3-year time-period, e.g., a lab interpretation is billed and no E/M service or other face-to-face service with the patient is performed, then this patient remains a new patient for the initial visit. An interpretation of a diagnostic test, reading an x-ray or EKG etc., in the absence of an E/M service or other face-to-face service with the patient does not affect the designation of a new patient. Beginning in 2012, the AMA CPT instructions for billing new patient visits include physicians in the same specialty and subspecialty. However, for Medicare E/M services the same specialty is determined by the physician's or practitioner's primary specialty enrollment in Medicare. Recognized Medicare specialties can be found in the Medicare Claims Processing Manual, chapter 26 (http://www.cms.gov/manuals/downloads/clm104c26.pdf). You may contact your Medicare claims processing contractor to confirm your primary Medicare specialty designation. (FAQ1969)
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A self-insured health plan must answer two questions to determine whether it must obtain an HPID.• Does it meet... (more)

A self-insured health plan must answer two questions to determine whether it must obtain an HPID.• Does it meet the definition of health plan under 45 CFR 160.103? A health plan is an individual or group plan that provides or pays the cost of medical care (as defined in 45 CFR 160.103). • If it meets the definition of a health plan, is it a controlling health plan (CHP)? A CHP is a health plan that controls its own business activities, actions, or policies, or is controlled by an entity that is not a health plan. A health plan is also a CHP if it has one or more sub health plans that it controls by directing the SHP’s business activities, actions, or policies.

FSAs and HSAs are individual accounts directed by the consumer to pay health care costs. As such, they do not r... (more)

FSAs and HSAs are individual accounts directed by the consumer to pay health care costs. As such, they do not require an HPID.

HRAs that cover only deductibles or out-of-pocket costs, or both, do not require HPIDs as these are more like additional plan benefits than stand-alone plans. If an HRA does not coordinate with other health coverage, but instead is designed to provide an individual's primary health coverage, the HRA might be required to obtain an HPID if it otherwise meets the definition of a health plan.

Cafeteria plans are not health plans and thus are not required to obtain an HPID.

See the FAQ# 10848 “Which group health plans must obtain HPIDs?” for more information on obtaining an HPID for group health plans.

To meet the “Protect Electronic Health Information” core objective for Stage 1, eligible professionals (EP), eligible hospitals or critical access hospitals (CAH) must conduct or review a security risk analysis in accordance with the requirements under 45 CFR 164.308(a)(1) and implement security updates as necessary and correct identified security deficiencies as part of the provider's risk management process.

In Stage 2, in addition to meeting the same security risk analysis requirements as Stage 1, EPs and hospitals will also need to address the encryption and security of data stored in the certified EHR technology (CEHRT).

These steps may be completed outside or the EHR reporting period timeframe but must take place no earlier than the start of the EHR reporting year and no later than the provider attestation date. For example, a EP who is reporting Meaningful Use for a 90-day EHR reporting period may complete the appropriate security risk analysis requirements outside of this 90-day period as long as it is completed no earlier than January 1st of the EHR reporting year and no later than the date the provider submits their attestation for that EHR reporting period.

This meaningful use objective complements but does not impose new or expanded requirements on the HIPAA Security Rule. In accordance with the requirements under (45 CFR 164.308(a)(1)(ii)), providers are required to conduct an accurate and thorough analysis of the potential risks and vulnerabilities to the confidentiality, integrity, and availability of electronic protected health information (ePHI). Once the risk analysis is completed, providers must take any additional “reasonable and appropriate” steps to reduce identified risks to reasonable and appropriate levels.

Please note that a security risk analysis or review needs to be conducted during each EHR reporting year for Stage 1 and Stage 2 of meaningful use to ensure the privacy and security of their patients’ protected health information.

For more information about completing a security risk analysis, please see the following resources:

Eligible professionals participating in Stage 1 of the EHR Incentive Programs are required to report on a total of 5 ... (more)

Eligible professionals participating in Stage 1 of the EHR Incentive Programs are required to report on a total of 5 meaningful use objectives from the menu set of 9 objectives. When selecting five objectives from the menu set, eligible professionals must choose at least one option from the public health menu set. If an eligible professional is able to meet the measure of one of the public health menu objectives but can be excluded from the other, he or she should select and report on the public health menu objective he or she is able to meet.If an eligible professional can be excluded from both public health menu objectives, he or she may meet the menu requirement one of two ways:

1. Claim an exclusion from only one public health objective and report on four additional menu objectives from outside the public health menu set.2. Report on five menu objectives from outside the public health menu set.Eligible professionals participating in Stage 2 are required to report 3 meaningful use objectives from the menu set of 6.We encourage eligible professionals to select menu objectives that are relevant to their scope of practice, and claim an exclusion for a menu objective only in cases where there are no remaining menu objectives for which they qualify or if there are no remaining menu objectives that are relevant to their scope of practice. For example, we hope that eligible professionals will report on 5 measures, if there are 5 measures that are relevant to their scope of practice and for which they can report data, even if they qualify for exclusions in the other objectives.The CMS Registration and Attestation System may prompt a Medicare eligible professional to report on additional measures if he or she claims an exclusion. This is because starting in 2014, the exclusion criteria will no longer count as reporting a meaningful use objective from the menu set. A Medicare eligible professional must meet the measure criteria for the objectives or report on all of the menu set objectives through a combination of meeting exclusion and meeting the measure.

However, some Medicare eligible professionals who elect option 1 above may be asked to report on non-public health measures when they claim that exclusion in the CMS attestation system. These providers should document this issue for their records and then claim the exclusion for the remaining measures in order to allow the attestation system to accept their attestation. For more information about the Medicare and Medicaid EHR Incentive Program, please visithttp://www.cms.gov/EHRIncentivePrograms.

EPs and group practices are not required to have 2014 CEHRT for the full year of PQRS or have 2014 CEHRT implemented ... (more)

EPs and group practices are not required to have 2014 CEHRT for the full year of PQRS or have 2014 CEHRT implemented on the first day of the reporting year, which is 1/1/2014. However, in order to participate in PQRS via an EHR-based reporting mechanism, EPs and group practices must submit the final set of data utilizing 2014 CEHRT. The EP or group practice will only be able to participate in 2014 PQRS if the new TIN implements 2014 CEHRT in time for submission. Therefore, EPs and group practices in this scenario will have access to a full year of data via 2014 CEHRT and will be able to participate in both the 2014 EHR Incentive Program and PQRS via EHR reporting method.

Please note that group practices participating in 2014 PQRS through the group practice reporting option (GPRO) via Web Interface are also required to use 2014 CEHRT to populate the Web Interface when participating in 2014 PQRS and the EHR Incentive Program.

Please contact the QualityNet Help Desk at 1-866-288-8912 (TTY 1-877-715-6222) or via qnetsupport@hcqis.org for help with questions. They are available from 7:00 a.m. to 7:00 p.m. CST Monday through Friday.

An EP, eligible hospital, or CAH could use 3 distinct approaches (which could also be used in combination) to meet th... (more)

An EP, eligible hospital, or CAH could use 3 distinct approaches (which could also be used in combination) to meet this measure. The first two rely solely on the use of CEHRT, while the third is slightly different.

For the first two approaches, this measure can only be met if the EP, eligible hospital, or CAH uses the capabilities and standards included as part of its Certified EHR Technology (CEHRT) to electronically transmit summary care records for transitions of care and referrals (specifically those capabilities certified to the certification criterion adopted by ONC at 45 CFR 170.314(b)(2) “transitions of care – create and transmit transition of care/referral summaries,” which specifies standards for data content and transport).

For the third approach, the EP, eligible hospital, or CAH must use its CEHRT to create a summary care record for transitions of care and referrals, but instead of using a transport standard specified in ONC’s certification criterion at 45 CFR 170.314(b)(2) (included as part of its CEHRT) to electronically transmit the summary care record, the EP, eligible hospital, or CAH may use a NwHIN Exchange participant to facilitate the electronic transmission to the recipient. The NwHIN Exchange is now known as “eHealth Exchange” and a list of participants can be found here.

The following are more detailed explanations of each permitted approach. We also emphasize that regardless of the way an EP, eligible hospital, or CAH chooses to transmit the summary of care record, such a transmission will only count in the numerator if it is received by the provider to whom the sending provider is referring or transferring the patient.

1. Use of the transport standard capability required for certification. As required by ONC to meet the CEHRT definition, every EP, eligible hospital, and CAH, must have EHR technology that is capable of electronically transmitting a summary care record for transitions of care and referrals according to the primary Direct Project specification (the Applicability Statement for Secure Health Transport). Thus, EPs, eligible hospitals, or CAHs that electronically transmit summary care records using their CEHRT’s “Direct” capability (natively or combined with an intermediary) would be able to count all such electronic transmissions in their numerator.

2. Use of the SOAP-based optional transport standard capability permitted for certification. As part of certification, ONC permits EHR technology developers to voluntarily seek certification for their EHR technology’s capability to perform SOAP-based electronic transmissions. EHR technology developers who take this approach would enable their customers to also use this approach to meet the measure. Thus, EPs, eligible hospitals, or CAHs that electronically transmit summary care records using their CEHRT’s “SOAP-based” capability (natively or combined with an intermediary) would be able to count all of those transmissions in their numerator.

3. Use of CEHRT to create a summary care record in accordance with the required standard (i.e., Consolidated CDA as specified in 45 CFR 170.314(b)(2)), and the electronic transmission is accomplished through the use of an eHealth Exchange participant who enables the electronic transmission of the summary care record to its intended recipient. Thus, EPs, eligible hospitals, or CAHs who create standardized summary care records using their CEHRT and then use an eHealth Exchange participant to electronically transmit the summary care record would be able to count all of those transmissions in their numerator.

We note that for this third approach, the regulation also permits an EP, eligible hospital, or CAH to count in their numerator instances where a summary care record for transitions of care or referrals was received via electronic exchange facilitated in a manner consistent with the governance mechanism ONC establishes for the nationwide health information network. ONC has not yet established a governance mechanism for the nationwide health information network. Until ONC establishes such a governance mechanism, this specific option will not be available.

Yes. An EP, eligible hospital or CAH may count transmissions in this measure’s numerator when a third party org... (more)

Yes. An EP, eligible hospital or CAH may count transmissions in this measure’s numerator when a third party organization is involved so long as:

• The summary of care document is created using certified EHR technology (CEHRT);

• The summary of care document electronically transmitted by the EP, eligible hospital or CAH to the third party organization is done so using EITHER:(a) their CEHRT’s transport standard capability; or (b) an exchange facilitated by an organization that is an eHealth Exchange participant.

• The third party organization can confirm for the sending provider that the summary of care document was ultimately received by the next provider of care.

In instances where a “third party organization that plays a role in determining the next provider of care and ultimately delivers the summary of care document” is involved, the service the third party provides does not have to be certified for the transmission to be counted in the numerator for measure 2. Nor are there any specific requirements around the technical standards or methods by which the third party delivers the summary of care document to the receiving provider (e.g., SOAP, secure email, fax).

For more information about the Summary of Care objective, please see FAQ 9690.

This FAQ applies to providers who are reporting 2013 CQMs.
Eligible professionals (EP) are not... (more)

This FAQ applies to providers who are reporting 2013 CQMs.

Eligible professionals (EP) are not excluded from reporting CQMs, but zero is an acceptable value for the CQM denominator. If there were no patients who met the denominator population for a CQM, then the EP would report a zero for the denominator and a zero for the numerator. For the core measures, if the EP reports a zero for the core measure denominator, then the EP must report results for up to three alternate core measures (potentially reporting on all 6 core/alternate core measures). For the menu-set measures, we expect the EP to report on measures which do not have a denominator of zero. If none of the measures in the menu set applies to the EP, then the EP must report on three of such measures, reporting a denominator of zero, and then attest that the remainder of the menu-set measures has a value of zero in the denominator. As we stated in the final rule (75 FR 44409-10): "The expectation is that the EHR will automatically report on each core clinical quality measure, and when one or more of the core measures has a denominator of zero then the alternate core measure(s) will be reported. If all six of the clinical quality measures in Table 7 have zeroes for the denominators (this would imply that the EPs patient population is not addressed by these measures), then the EP is still required to report on three additional clinical measures of their choosing from Table 6 in this final rule. In regard to the three additional clinical quality measures, if the EP reports zero values, then for the remaining clinical quality measures in Table 6 (other than the core and alternate core measures) the EP will have to attest that all of the other clinical quality measures calculated by the certified EHR technology have a value of zero in the denominator, if the EP is to be exempt from reporting any of the additional clinical quality measures (other than the core and alternate core measures) in Table 6."

In order to enumerate (obtain an HPID), a health plan should:1. Create an account in the ... (more)

In order to enumerate (obtain an HPID), a health plan should:1. Create an account in the CMS Enterprise Portal to obtain a user ID and password.2. Select the link to register in the Health Insurance Oversight System (HIOS).3. After registering in HIOS, select the link for the Health Plan and Other Entity Enumeration System (HPOES), and follow the prompts.

Health Insurance Issuers (Carriers) are required to obtain HPIDs, as they are controlling health plans. Fully-insured Group Health Plans are not required to obtain a separate HPID. If you need to know your Carrier's HPID, then you may contact them for that information.

Any licensed healthcare professional can enter orders into the medical record for purposes of including the order in the... (more)

Any licensed healthcare professional can enter orders into the medical record for purposes of including the order in the numerator for the measure of the CPOE objective if they can enter the order per state, local, and professional guidelines. The order must be entered by someone who could exercise clinical judgment in the case that the entry generates any alerts about possible interactions or other clinical decision support aides. This necessitates that CPOE occurs when the order first becomes part of the patient's medical record and before any action can be taken on the order. Each provider will have to evaluate on a case-by-case basis whether a given situation is entered according to state, local, and professional guidelines, allows for clinical judgment before the medication is given, and is the first time the order becomes part of the patient's medical record.

There are two methods for calculating ED admissions for the denominators for measures associated with Meaningful Use ... (more)

There are two methods for calculating ED admissions for the denominators for measures associated with Meaningful Use objectives. Eligible hospitals and CAHs must select one of the methods below for calculating ED admissions to be applied consistently to all denominators for the measures. That is, eligible hospitals and CAHs must choose either the “Observation Services method” or the “All ED Visits method” to be used with all measures. Providers cannot calculate the denominator of some measures using the “Observation Services method,” while using the “All ED Visits method” for the denominator of other measures. Before attesting, eligible hospitals and CAHs will have to indicate which method they used in the calculation of denominators.

Observation Services method. When using this method, the denominator should include the following visits to the ED:

• The patients who are admitted to the inpatient department (Place of Service (POS) 21) either directly or through the emergency department.• The patients who are initially presented to the emergency department (POS 23) and receive observation services. Patients who receive observation services under both POS 22 and POS 23 should be included in the denominator. Details on observation services can be found in the Medicare Benefit Policy Manual, Chapter 6, Section 20.6.

All ED Visits method. An alternate method for computing admissions to the ED is to include all ED visits (POS 23 only) in the denominator for all measures requiring inclusion of ED admissions. All actions taken in the inpatient or emergency departments (POS 21 and 23) of the hospital would count for purposes of determining meaningful use.

In order to receive Medicare EHR incentive payments, EPs, eligible hospitals, and critical access hospitals must have an enrollment record in PECOS with an APPROVED status. Medicaid EPs do not have to be in PECOS. It is possible to receive payment for Medicare claims and not be in approved status. We encourage all providers to verify their status as soon as possible.

There are three ways to verify that you have an enrollment record in PECOS:

1. Check the Ordering Referring Report on the CMS website. If you are on that report, you have a current enrollment record in PECOS. Go to http://www.cms.gov/MedicareProviderSupEnroll/, click on "Ordering Referring Report" on the left.

2. Use Internet-based PECOS to look for your PECOS enrollment record. If no record is displayed, you do not have an enrollment record in PECOS. Go to http://www.cms.gov/MedicareProviderSupEnroll/, click on "Internet-based PECOS" on the left.

3. Contact your designated Medicare enrollment contractor and ask if you have an enrollment record in PECOS. Go to http://www.cms.gov/MedicareProviderSupEnroll/, click on "Medicare Fee-For-Service Contact Information" under "Downloads."

For 2014 PQRS eCQMs, the expectation is that eligible professionals (EPs) or group practices reporting via the Group ... (more)

For 2014 PQRS eCQMs, the expectation is that eligible professionals (EPs) or group practices reporting via the Group Practice Reporting Option (GPRO) select 9 measures and 3 domains applicable to their practice, or report on as many measures and domains as they have available (up to 9 measures/3 domains) within their CEHRT EHR and with applicable Medicare patient data. If more than 9 measures are applicable, then EPs/group practices can select the 9 most appropriate for their practice (or can report on as many applicable measures over 9 as desired).

EPs/group practices can earn a 2014 PQRS incentive and avoid the 2016 PQRS payment adjustment by meeting the following criteria for satisfactory reporting:

1. Using a direct EHR product that is Certified EHR Technology (CEHRT) or EHR data submission vendor that is CEHRT, report on at least 9 measures covering 3 National Quality Strategy (NQS) domains.

• If the EP’s CEHRT does not contain patient data for at least 9 measures covering at least 3 domains, then the EP must report the measures for which there is Medicare patient data. An EP must report on at least 1 measure for which there is Medicare patient data to earn the 2014 PQRS incentive and avoid the 2016 PQRS payment adjustment.

The 0% performance rate rule, where no patients in the denominator are in compliance and/or receive the correct quality action rule, does not apply to 2014 PQRS eCQMs. However, EPs should be aware that the VBM program, performance on eCQMs will be included when calculating the VBM. An EP must report on at least 1 measure with Medicare patient data meeting the denominator criteria, but the one patient does not need to meet numerator criteria.

Note: This rule is not applicable to groups reporting via GPRO web interface. Those groups must report all 22 GPRO WI measures both to earn a 2014 incentive and to avoid the 2016 payment adjustment.

If an EP/group practice has no applicable eCQMs with Medicare data, (s)he should choose a different reporting option for 2014 PQRS.

Please contact the QualityNet Help Desk at 1-866-288-8912 (TTY 1-877-715-6222) or via qnetsupport@hcqis.org for help with questions. They are available from 7:00 a.m. to 7:00 p.m. CST Monday through Friday.

A controlling health plan (CHP) must obtain an HPID by November 5, 2014, unless it is a small health plan (annual receip... (more)

A controlling health plan (CHP) must obtain an HPID by November 5, 2014, unless it is a small health plan (annual receipts of $5 million or less). Small health must obtain an HPID by November 5, 2015. (FAQ10700)
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Beginning in 2015, CMS will subject eligible professionals who are not successful reporters under Physician Quality R... (more)

Beginning in 2015, CMS will subject eligible professionals who are not successful reporters under Physician Quality Reporting to a payment adjustment. To avoid the 2015 Physician Quality Reporting payment adjustment, eligible professionals must successfully report during the 2013 reporting period (January 1, 2013 – December 31, 2013).

If subject to the 2015 Physician Quality Reporting payment adjustment, eligible professionals will be paid 1.5% less than the Medicare Physician Fee Schedule (PFS) amount for services rendered in 2015. In 2016 and each subsequent year, the payment adjustment increases to 2.0%. The payment adjustment will be applied to all of the eligible professional's Part B-covered professional services under the Medicare PFS.

Additional information about how to avoid the Physician Quality Reporting System payment adjustment is available on CMS website. Please refer to the document titled 2013 PQRS: 2015 Payment Adjustment Tip Sheet at:

A transition of care is defined as the movement of a patient from one setting of care (hospital, ambulatory, primary ... (more)

A transition of care is defined as the movement of a patient from one setting of care (hospital, ambulatory, primary care practice, ambulatory specialty care practice, long-term care, home health, rehabilitation facility) to another. To count toward the Summary of Care objective, the transition or referral must take place between providers with different billing identities such as a different National Provider Identifier (NPI) or hospital CMS Certification Number (CCN).

For Measure 1 of the Summary of Care objective, include the transitions of care in which a summary of care document was provided to the recipient of the transition or referral by any means.

For Measure 2 of the Summary of Care objective, include the transitions of care in which a summary of care document was transmitted electronically using a Certified EHR Technology (CEHRT) to the recipient, or via exchange facilitated by an organization that is an eHealth Exchange participant, or in a manner that is consistent with the governance mechanism ONC establishes for the nationwide health information network.

If the receiving provider already has access to the CEHRT of the initiating provider of the transition or referral, simply accessing the patient’s health information does not count toward meeting this objective. However, if the initiating provider also sends a summary of care document, this transition can be included in the denominator and the numerator as long as it is counted consistently across the organization and across both measures If:• For Measure 1, a summary of care document is also provided by any means.• For Measure 2, a summary of care document is provided using the same technical standards used if the receiving provider did not have access to the CEHRT,

For Measure 3 of the Summary of Care objective, a single summary of care document sent to a provider using a different EHR and EHR Vendor or a test with the CMS and ONC Randomizer test system would meet the measure.

Take the following steps to begin claims-based reporting for Physician Quality Reporting: 1). Use the measure specificat... (more)

Take the following steps to begin claims-based reporting for Physician Quality Reporting: 1). Use the measure specifications to identify measures applicable for professional services you routinely provide. 2). Select those measures that make sense based upon prevalence and volume in your practice as well as your individual or practice performance analysis and improvement priorities. 3). Review the measures that you have selected to become familiar with how to apply and correctly code the measures. 4). Refer to the Physician Quality Reporting System Implementation Guide for more detailed information and reporting tips at http://www.cms.gov/PQRS/15_MeasuresCodes.asp. 5). Access data collection worksheets on the American Medical Association's (AMA) website (http://www.ama-assn.org/ama) to help you implement Physician Quality Reporting in your practice. 6) Ensure that your billing software and clearinghouse can correctly submit Physician Quality Reporting quality-data codes (QDCs) on your behalf to the carrier. 7) Regularly review the Remittance Advice Notice you receive from the Carrier/Medicare Administrative Contractor (MAC) to ensure the denial remark code N365 is listed for each QDC submitted.

If a staff member of the eligible provider is appropriately credentialed and performs similar assistive services as a... (more)

If a staff member of the eligible provider is appropriately credentialed and performs similar assistive services as a medical assistant but carries a more specific title due to either specialization of their duties or to the specialty of the medical professional they assist, he or she can use the CPOE function of CEHRT and have it count towards the measure. This determination must be made by the eligible provider based on individual workflow and the duties performed by the staff member in question. Whether a staff member carries the title of medical assistant or another job title, he or she must be credentialed to perform the medical assistant services by an organization other than the employing organization. Also, each provider must evaluate his or her own ordering workflow, including the use of CPOE, to ensure compliance with all applicable federal, state, and local law and professional guidelines.

Any provider attesting to receive an EHR incentive payment for either the Medicare or Medicaid EHR Incentive Program ... (more)

Any provider attesting to receive an EHR incentive payment for either the Medicare or Medicaid EHR Incentive Program potentially can be subject to an audit. Here's what you need to know to make sure you're prepared:Overview of the CMS EHR Incentive Programs Audits• All providers attesting to receive an EHR incentive payment for either the Medicare or Medicaid EHR Incentive Programs should retain ALL relevant supporting documentation (in either paper or electronic format) used in the completion of the Attestation Module responses. Documentation to support the attestation should be retained for six years post-attestation. Documentation to support payment calculations (such as cost report data) should continue to follow the current documentation retention processes.• CMS, and its contractors, will perform audits on Medicare and dually-eligible (Medicare and Medicaid) providers.• States, and their contractors, will perform audits on Medicaid providers.• CMS and states will also manage appeals processes.Preparing for an Audit• To ensure you are prepared for a potential audit, save the electronic or paper documentation that supports your attestation. Also save the documentation that supports the values you entered in the Attestation Module for Clinical Quality Measures (CQMs). Hospitals should also maintain documentation that supports their payment calculations.• Upon audit, the documentation will be used to validate that the provider accurately attested and submitted CQMs, as well as to verify that the incentive payment was accurate.Details of the Audits• There are numerous pre-payment edit checks built into the EHR Incentive Programs' systems to detect inaccuracies in eligibility, reporting, and payment. • Post-payment audits will also be completed during the course of the EHR Incentive Programs.• Medicare audit notification will come from Figliozzi and Company, or the EHR Meaningful Use Audit Team• If, based on an audit, a provider is found to not be eligible for an EHR incentive payment, the payment will be recouped. • CMS has an appeals process for eligible professionals, eligible hospitals, and critical access hospitals that participate in the Medicare EHR Incentive Program.• States will implement appeals processes for the Medicaid EHR Incentive Program. For more information about these appeals, please contact your State Medicaid Agency.What information should an eligible professional, eligible hospital, or critical access hospital participating in the Medicare or Medicaid Electronic Health Record (EHR) Incentive Programs maintain in case of an audit?An audit may include a review of any of the documentation needed to support the information that was entered in the attestation. The level of the audit review may depend on a number of factors, and it is not possible to include an all-inclusive list of supporting documents. The primary documentation that will be requested in all reviews is the source document(s) that the provider used when completing the attestation. This document should provide a summary of the data that supports the information entered during attestation. Ideally, this would be a report from the certified EHR system, but other documentation may be used if a report is not available or the information entered differs from the report. This summary document will be the starting point of most reviews and should include, at minimum:• The numerators and denominators for the measures• The time period the report covers • Evidence to support that it was generated for that eligible professional, eligible hospital, or critical access hospital.Although the summary document is the primary review step, there could be additional and more detailed reviews of any of the measures, including review of medical records and patient records. The provider should be able to provide documentation to support each measure to which he or she attested, including any exclusions claimed by the provider. A few examples of additional support are as follows:• Drug-Drug/Drug-Allergy Interaction Checks and Clinical Decision Support – Proof that the functionality is available, enabled, and active in the system for the duration of the EHR reporting period.• Electronic Exchange of Clinical Information – Screenshots from the EHR system or other documentation that document a test exchange of key clinical information (successful or unsuccessful) with another provider of care. Alternately, a letter or email from the receiving provider confirming the exchange, including specific information such as the date of the exchange, name of providers, and whether the test was successful.• Protect Electronic Health Information – Proof that a security risk analysis of the certified EHR technology was performed prior to the end of the reporting period (e.g., report which documents the procedures performed during the analysis and the results). • Drug Formulary Checks – Proof that the functionality is available, enabled, and active in the system for the duration of the EHR reporting period.• Immunization Registries Data Submission, Reportable Lab Results to Public Health Agencies, and Syndromic Surveillance Data Submission– Screenshots from the EHR system or other documentation that document a test submission to the registry or public health agency (successful or unsuccessful). Alternately, a letter or email from registry or public health agency confirming the receipt (or failure of receipt) of the submitted data, including the date of the submission, name of parties involved, and whether the test was successful. • Exclusions – Documentation to support each exclusion to a measure claimed by the provider. For Medicare eligible professionals and for hospitals that are eligible for both Medicare and Medicaid EHR incentive payments - When a provider is selected for an audit, they will receive an initial request letter from the audit contractor. The request letter will be sent electronically by the audit contractor from a CMS email address and will include the audit contractor’s contact information. The email address provided during registration for the EHR Incentive Program will be used for the initial request letter.The initial review process will be conducted at the audit contractor’s location, using the information received as a result of the initial request letter. Additional information might be needed during or after this initial review process, and in some cases an on-site review at the provider’s location could follow. A demonstration of the EHR system could be requested during the on-site review. A secure communication process has been established by the contractor, which will assist the provider to send any information that could be considered sensitive. Any questions pertaining to the information request should be directed to the audit contractor.States will have separate audit processes for their Medicaid EHR Incentive Program. For more information about these audit processes, please contact your State Medicaid Agency.

There are 15 measures for EPs and 14 measures for eligible hospitals that require the collection of data to calculate a ... (more)

There are 15 measures for EPs and 14 measures for eligible hospitals that require the collection of data to calculate a percentage, which will be the basis for determining if the Meaningful Use objective was met according to a minimum threshold for that objective.

Objectives requiring a numerator and denominator to generate this calculation are divided into two groups: one where the denominator is based on patients seen or admitted during the EHR reporting period, regardless of whether their records are maintained using certified EHR technology; and a second group where the objective is not relevant to all patients either due to limitations (e.g., recording tobacco use for all patients 13 and older) or because the action related to the objective is not relevant (e.g., transmitting prescriptions electronically). For these objectives, the denominator is based on actions related to patients whose records are maintained using certified EHR technology. This grouping is designed to reduce the burden on providers. Table 3 in the Medicare and Medicaid EHR Incentive programs final rule (FR 75 44376 - 44380) lists measures sorted by the method of measure calculation. To view the final rule, please visit: http://edocket.access.gpo.gov/2010/pdf/2010-17207.pdf.

Fully-insured Group Health Plans are not exempt from the HPID requirements. However, they are not required to obta... (more)

Fully-insured Group Health Plans are not exempt from the HPID requirements. However, they are not required to obtain a separate HPID as the Health Insurance Issuers (Carriers) have already obtained them.

We have revised the description of who can enter orders into the EHR and have it count as CPOE and have it count for pur... (more)

We have revised the description of who can enter orders into the EHR and have it count as CPOE and have it count for purposes of the CPOE measure. This revision is available for EHR reporting periods in 2013 and beyond regardless of what stage of meaningful use the provider is attesting to. (FAQ7693)
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MAV is a validation process that will determine whether individual eligible professionals (EPs) or group practices sh... (more)

MAV is a validation process that will determine whether individual eligible professionals (EPs) or group practices should have reported additional measures OR additional domains. MAV determines 2014 Physician Quality Reporting System (PQRS) incentive eligibility and 2016 PQRS payment adjustment status for individual EPs and group practices. In the instance an individual EP or group practice has satisfactorily reported nine or more measures across three or more domains, MAV would not apply and the individual EP or group practice could earn the 2014 PQRS incentive and avoid the 2016 PQRS payment adjustment.

MAV is applied to individual EPs and group practices that report less than nine measures OR less than three domains for PQRS. If MAV analytically determines that the EP or group practice could have reported additional measures or domains within the clinical cluster, then the 2014 PQRS incentive would not be earned and the 2016 PQRS payment adjustment may apply. Claims-based MAV is applicable to individual EPs, whereas registry-based MAV is applicable to individual EPs and group practices.

Please contact the QualityNet help desk at 1-866-288-8912 or via the new e-mail address at qnetsupport@hcqis.org should you have any additional questions.

Yes. The HPID final rule at 45 CFR 162.506 adopted the HPID for identification of all entities that meet the definition of a health plan. If the health plan is a controlling health plan, then it is required to get an HPID.

A controlling health plan (CHP) must obtain an HPID by November 5, 2014, unless it is a small health plan (annual rec... (more)

A controlling health plan (CHP) must obtain an HPID by November 5, 2014, unless it is a small health plan (annual receipts of $5 million or less). Small health plans must obtain an HPID by November 5, 2015. A small Health Plan is a health plan with annual receipts of not more than $5 million is a small health plan. Health plans that file certain federal tax returns and report receipts on those returns should use the guidance provided by the Small Business Administration at 13 Code of Federal Regulations (CFR) 121.104 to calculate annual receipts. Health plans that do not report receipts to the Internal Revenue Service (IRS), for example, group health plans regulated by the Employee Retirement Income Security Act 1974 (ERISA) that are exempt from filing income tax returns, should use proxy measures to determine their annual receipts.

Fully insured health plans should use the amount of total premiums that they paid for health insurance benefits during the plan’s last full fiscal year. Self-insured plans, both funded and unfunded, should use the total amount paid for health care claims by the employer, plan sponsor or benefit fund, as applicable to their circumstances, on behalf of the plan during the plan’s last full fiscal year. Those plans that provide health benefits through a mix of purchased insurance and self-insurance should combine proxy measures to determine their total annual receipts.

A health plan (as defined in 45 CFR 160.103) is an individual plan or group health plan that provides or pays the cost of medical care. The term “payer” is an industry term and may include a health plan, but may also designate other entities that do not meet the definition of a health plan, such as a third party administrator (TPA). (FAQ10692)
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Yes. This transitive effect applies to the Secure Messaging and the 2nd measure of the Patient Access (View, Do... (more)

Yes. This transitive effect applies to the Secure Messaging and the 2nd measure of the Patient Access (View, Download and Transmit) core objectives.

If a patient sends a secure message about a clinical or health related subject to the group practice of their EP, that patient can be counted in the numerator of the Secure Messaging measure for any of the EPs at the group practice who use the same certified electronic health records technology (CEHRT) that saw and patient during their EHR reporting period.

Similarly, if a patient views, downloads or transmits to a third party the health information that was made available online by their EP, that patient can be counted in the numerator of the 2nd Patient Access measure for any of the EPs in that group practice who use the same CEHRT and saw that patient during their EHR reporting period.

The criteria for a numerator is not constrained to the EHR reporting period unless expressly stated in the numerator ... (more)

The criteria for a numerator is not constrained to the EHR reporting period unless expressly stated in the numerator statement for a given meaningful use measure. The numerator for the following meaningful use measures should include only actions that take place within the EHR reporting period: Preventive Care (Patient Reminders) and Secure Electronic Messaging.

For all other meaningful use measures, the actions may reasonably fall outside the EHR reporting period timeframe but must take place no earlier than the start of the reporting year and no later than the date of attestation in order for the patients to be counted in the numerator, unless a longer look-back period is specifically indicated for the objective or measure.

CMS is aware of difficulties eligible professionals, eligible hospitals, and critical access hospitals (CAHs) are having in use of the CMS Designated Test EHRs (NIST EHR-Randomizer Application) to meet measure 3 of the Stage 2 Summary of Care objective. At this time the two CMS Designated Test EHRs can only exchange/match with an eligible professional or eligible hospital that is Direct Trust (DT) Accredited. There is not a non-DT Accredited Test EHR for providers to use to successfully complete the test.

The following actions are currently in place to meet the Summary of Care objective for measure 3:

1. Exchange a summary of care with a provider or third party who has different CEHRT as the sending provider as part of the 10% threshold for measure #2. A successful exchange in measure #2 allows the provider to meet the criteria for measure #3 without the need to conduct a test with the Randomizer as outlined in measure #3, or

2. Conduct at least one successful test with the CMS designated test EHR (if the provider is Direct Trust Accredited).

If providers do not exchange summary of care documents with recipients using a different CEHRT in common practice, and cannot use the CMS Designated Test EHR for the reasons outlined above, they may retain documentation on their circumstances and attest “Yes” to meeting measure #3 if they have and are using a certified EHR which meets the standards required to send a CCDA (§ 170.202).

This exchange may be conducted outside of the EHR reporting period timeframe, but must take place no earlier than the start of the year and no later than the end of the EHR reporting year or the attestation date, whichever occurs first.

For example, an eligible professional or eligible hospital that is reporting meaningful use for a 90-day EHR reporting period may conduct this exchange outside of this 90-day period as long as it is completed no earlier than the first day of the EHR reporting year and no later than the last day of the EHR reporting year.

• Brachytherapy sources;
• Certain implantable items with pass-through status under the OPPS;
• Certain items and services that CMS designates as contractor-priced, including, but not limited to, the procurement of corneal tissue;
• Certain drugs and biologicals for which separate payment is allowed under the OPPS; and
• Certain radiology services for which separate payment is allowed under the OPPS.

Other non-ASC services such as physician services and prosthetic devices may be covered and separately billed under Medicare Part B. See the Medicare Claims Processing Manual, Chapter 14, Section 10.2 for more information.

If the eligible professional (EP) reporting as an individual PQRS reporter (and not part of a group practice using the Group Practice Reporting Option (GPRO)) achieves satisfactory reporting under more than one reporting option, the EP will receive the incentive payment for the most advantageous reporting method for which he/she qualifies. There is no penalty if multiple options are attempted. CMS will review data submitted via one or more reporting methods to determine satisfactory reporting and eligibility for an incentive payment of a percentage of the Medicare Part B Physician Fee Schedule (PFS) total estimated allowed charges during the reporting period.

For those reporting as individual PQRS reporters using the registry submission method, it is acceptable to use multiple registries within the same reporting year to submit PQRS data, even for the same measures. Data analysis will determine if satisfactory reporting was achieved for each registry in which the individual EP within the TIN participated, and the most favorable outcome will be used (but results from multiple vendors will not be combined). Submitting PQRS data to several registries may increase the EP’s chance of satisfactory reporting, in case one registry was not successful (the same applies to EHR-based reporting using Certified EHR Technology (CEHRT).

However, a group practice reporting via GPRO using a registry must submit for the group through one registry.

EPs who are providers/suppliers in ACO participant TINs in the Medicare Shared Savings Program (SSP) may NOT earn a PQRS incentive/avoid the payment adjustment outside of their ACO reporting, per SSP regulation.

If reporting for PQRS through another CMS program (such as the Medicare Shared Savings Program, Comprehensive Primary Care Initiative, Pioneer Accountable Care Organizations), please check the program’s requirements for information on how to report quality data to earn a PQRS incentive and/or avoid the PQRS payment adjustment. Please note, although CMS has attempted to align or adopt similar reporting requirements across programs, eligible professionals should look to the respective quality program to ensure they satisfy the PQRS, EHR Incentive Program, Value-Based Payment Modifier (VBM), etc. requirements of each of these programs.

Please contact the QualityNet Help Desk at 1-866-288-8912 (TTY 1-877-715-6222) or via qnetsupport@hcqis.org for help with questions. They are available from 7:00 a.m. to 7:00 p.m. CST Monday through Friday.